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Address
1163 Baltic Avenue #229
Tiffin, IA 52340
Phone
319-325-1171
michael@mchristiansconsulting.com
319-325-1171
1163 Baltic Avenue #229 Tiffin, IA 52340
Contact
Recent Blog Posts
Each year, the Consumer Financial Protection Bureau and other federal government agencies are required to adjust a number of regulatory thresholds to account for inflation. Most adjustments are based on the annual percentage change in the Consumer Price Index. The following thresholds were effective January 1, 2026. Fannie Mae/Freddie Mac Conforming Loan Limits $832,750 ($1,249,125 for high-cost areas) Home Mortgage Disclosure Act Institutional Coverage Test A financial institution that meets the following four-part test is subject to HMDA: Assets in excess of $59 million as of 12/31/2025, Home or branch office in a Metropolitan Statistical Area (MSA), Originated at least one home purchase or refinance transaction in the preceding calendar year, and Federally insured or regulated. Qualified Mortgage Pricing Test First Lien Loans The APR charged in connection with the transaction does not exceed the current value of the APOR index by more than: 2.25% for loans greater than or equal to $137,958 3.50% for loans greater than or equal to $82,775 but less than $137,958 6.50% for loans less than $82,775 Subordinate Lien Loans The APR charged in connection with the transaction does not exceed the current value of the APOR index by more than: 3.50% for loans greater than or equal to $82,775 6.50% for loans less than $82,775 Qualified Mortgage Points and Fees Test Loans greater than $137,958 - 3% of the loan amount Loans between $82,775 and $137,958 - $4,139 Loans between $27,592 and $82,775 - 5% of the loan amount Loans between $17,245 and $27,592 - $1,380 Loans less than $17,245 - 8% of the loan amount Small Creditor Definition A financial institution that meets the following two-part test is considered a small creditor: During the preceding calendar year, the financial institution and its affiliates together originated 2,000 or fewer covered transactions secured by a first lien, and At the end of the preceding calendar year, the financial institution and its affiliates together had total assets of less than $2.785 billion. Higher Priced Mortgage Loan Appraisal Requirement Generally, in connection with a higher priced mortgage loan, a financial institution must obtain a written appraisal of the subject property. However, if one of the following exceptions applies, an alternative method of valuation may be used: The higher priced mortgage loan also meets the definition of a qualified mortgage, An extension of credit equal to or less than $34,200, A transaction secured by a mobile home, boat, or trailer, A construction loan, A bridge loan with a term of 12 months or less, or A reverse mortgage. High-Cost Mortgage Points and Fees Test A loan is considered high cost if the points and fees charged in connection with the transaction exceed: 5% of the loan amount for loans of $27,592 or greater For loans of less than $27,592, the lesser of - 8% of the loan amount, or $1,380 Credit Card Minimum Interest Charge A card issuer is required to disclose any minimum interest charge exceeding $1.00 that could be imposed during a billing cycle. Regulation Z Exemption An extension of credit in excess of $73,400 is exempt from Regulation Z unless it is: Secured by any real property or by personal property used by the consumer as his/her principal dwelling, or A private education loan. Regulation M Exemption A consumer lease with a total contractual obligation in excess of $73,400 is exempt from Regulation M.
The current funding authorization for the National Flood Insurance Program (NFIP) will expire on September 30, 2025, without Congressional action. The last long-term reauthorization of the NFIP occurred 13 years ago under the Biggert-Waters Flood Insurance Reform Act of 2012. Since then, Congress has only been able to reauthorize the program via short-term spending measures. If the NFIP is allowed to lapse on September 30th, borrowers will not be able to purchase new flood insurance contracts. Existing NFIP contracts will remain in effect until the end of their current one-year policy term. However, per the interagency Q&A regarding flood insurance, credit unions are permitted to close loans secured by property located in a special flood hazard area during the lapse period considering all of the following: They obtain a Standard Flood Hazard Determination in connection with the transaction, They provide the Notice of Special Flood Hazards within a reasonable period of time prior to closing, At its discretion, the credit union can require that closing be postponed until the NFIP is available again, At its discretion, the credit union can require that the borrower purchase a private flood insurance policy, and For loans closed during the lapse period without coverage, the credit union must have policies and procedures in place to require the purchase of flood insurance as soon as the NFIP is again active.
On September 3rd, Fannie Mae issued Selling Guide Announcement SEL-2025-07 , amending its reconsideration of value (ROV) requirements that went into effect in October 2024. Under the original rule, sellers were required to provide an ROV disclosure both at the time of application and again upon delivery of the appraisal copy to the applicant. The rule has been amended to require delivery of the ROV disclosure only at the time the appraisal copy is provided to the applicant. Freddie Mac followed suit in Bulletin 2025-12 and also removed the dual disclosure requirement. These changes come following HUD's elimination of all borrower-initiated ROV requirements in connection with FHA-insured loans.
Address
1163 Baltic Avenue #229
Tiffin, IA 52340
Phone
319-325-1171
michael@mchristiansconsulting.com
Michael Christians Consulting, LLC
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